How Coronavirus (COVID-19) affects UK private pilots

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During the current crisis, there has been a stream of notices, advice and guidance from the CAA, EASA and pilot organisations. It can be difficult to filter out the specific issues that affect private pilots, i.e. those with PPL, LAPL etc. and also spot what’s missing. It’s very easy to mix these up with derogations for commercial pilots. The CAA provided some exemption guidance in a simpler and easier to digest summary format in CAP 1946.

I’ve tried to simplify and clarify the key points below. This is a fairly fast changing situation, so while I have done my best you should beware that the statements below may already be incorrect or out of date.

Where can you fly?

Current government guidance on coronavirus generally permits recreational GA flying including instructional flights throughout the UK. The UK government retains authority over the skies but that is tempered by devolved regional and local authorities who might restrict movements in specific areas, for example local lockdowns.

Social distancing measures may prevent flying with anyone other that from your household, but the rules aren’t entirely clear to me. Most flying clubs/schools have reinstated flight instruction and solo hire, although many have not yet restarted Trial Lessons. Landaways are possible, although not all airfields are fully open so PPR essential, but you may find it better (and some clubs may mandate) that your first flight is a local one if you haven’t flown recently.

Foreign flights are possible (such as my day trip to Le Touquet), and requires submitting a couple of additional online declaration forms in advance. It’s unlikely to be worthwhile since you have to self-isolate for 14 days on your return unless you are flight crewing as part of your employment or an essential worker. The Channel Islands are not welcoming visitors (you will get tested on arrival and expected to self-isolate for 14 days). Scottish Islands are generally open, although Glenforsa Hotel will be closed for the season with the grass strip open. I was denied PPR in Shetland. The Scillies/St Mary’s is open. Ireland (north and south) are options, although Weston Airport (Dublin) is closed and not expected to reopen again.

The British Microlight Aircraft Association, new page 10384

Rating expiry dates extended to 30 November 2020

For those with an EASA LAPL or PPL, if your SEP, IRR or IR rating was valid on 16 March 2020 but expires before 31 October then it can be extended to 30 November based on a ground briefing from an instructor (which can be provided remotely). This also applies to non-EASA UK only licence holders including NPPL, UK PPL, UK CPL and UK ATPL where the rating expires before 31 July 2020. [ORS4 1385 for EASA licences, ORS4 1384 for UK licences]

For those who return to flying with an expired rating, then a short flight with an examiner will be required. This is a proficiency check rather than a skill test and can/should include some element of instruction. Although many pilots prefer to avoid anything considered a test, perhaps combining this with a general de-rusting/club check may be no bad thing.

For LAPL holders, the running expiry window is extended from 24 months to 32 months, also subject to the ground briefing from an instructor mentioned above. Failing that, you could choose between a proficiency check with an examiner and gaining the required recency by flight with and under supervision of an instructor. The benefit of the proficiency check is that it fully resets your LAPL currency for two years and you can immediately carry passengers.

SEP revalidation requires fewer flying hours

The measures above will let you return to flying for the current season, but you will again have to revalidate your SEP rating before it expires on 30 November. Normally to do that by experience, you’ll need to log the usual 12 hours flight time of which at least 6 are PIC, one is with an instructor and 12 take-offs/landings. The time period to log that remains the last 12 months prior to rating expiry, so that means between 30 November 2019 and 30 November 2020.

In order to make it easier, albeit more complex, the UK CAA will allow those with 8 or more hours flown in the previous year to revalidate if they’ve had 1.5 hours instruction with an FI/CRI and/or recorded more take-offs and landings. The full details are found in ORS4 1416 and ORS4 1417. This scheme is temporary and runs until 30 April 2021.

Temporary Certificates extended to 6 months

The one exception to the above is for those who have just passed their skill test or Assessment of Competence. If they have a temporary certificate issued by their examiner, the validity period has been extended from 8 weeks to 6 months, to allow the CAA to process their documentation. [ORS4 1373]

Pilot Medical, Class 1, £175, EASA, ATPL, CPL, Stressfree pilot checks

Medical Certificate expiry dates extended to between 22 November to 31 December

If your Class 2 or LAPL medical has expired, it isn’t easy to renew it in person at the moment. Many AME’s are now operating again with extra safety measures, although giving priority to commercial pilots, and have long waiting lists so book well ahead or consider use of the longer LAPL validity or Personal Medical Declaration.

In the circumstances, the CAA has issued two extensions for those with valid medical certificates held on 16 March 2020:

  • those expiring before 31 August 2020 to be extended through to 22 November 2020.
  • those expiring from 1st September 2020 are extended by 2020 or until 31 Dec 2020, whichever is sooner.

These regulations/alleviations are published in ORS4 1413 (EASA licences) and ORS4 1408 (National Licences)

In any case, if you normally have a Class 2 medical, you may find it comes with a longer LAPL validity. You can legally fly using a PPL licence and LAPL medical anywhere in Europe, restricted to LAPL privileges only, at least until 31 December 2020. However, that excludes acting as Flight Instructor/Examiner or flying IFR in an EASA aircraft.

You don’t need to apply for this extension, although you should carry a printed copy of the official notice (linked above) in case you were challenged. In my view, that’s unlikely to be a problem when in the UK.

Personal Medical Declaration

The PMD was introduced in 2016 and allowed PPL and LAPL holders to avoid the need to visit an AME. Provided they are healthy enough to drive a commercial truck and don’t suffer from one of a specific range of ailments, then can self-declare themselves as such. A one-off declaration is valid until aged 70, thereafter every three years. There is no cost to make a declaration, it just takes a few minutes on the CAA website. You must print out and carry the resulting declaration document with you alongside your pilot licence.

These cannot be used for flights outside the UK or for instructors/solo training.

The PMD is valid for both EASA and non-EASA aircraft. This privilege will remain valid for non-EASA aircraft permanently. It was recently extended to cover EASA aircraft up to November 2019, but only if the declaration was made on or before 8 April 2020. [ORS4 1370]

PPL or LAPL - The Private Pilot's Licence Options in the UK

UK PPL and NPPL no longer valid for EASA aircraft

It’s been some time in coming, but finally the deadline has passed. EASA has slowly been enforcing the requirement to hold an EASA licence to fly an EASA aircraft. This has been adopted quickly in many European countries, where there typically is no other licence available above that for a microlight.

In the days before pan-European regulations and licences from JAR and EASA, the UK simply issued its own ICAO compliant licences. These older UK PPLs remain valid even today, although most pilots would have converted.

The UK chose to issue their own national UK PPL licence when EASA licences were introduced, arguing that these were required to hold any non-EASA ratings. It has caused a lot of confusion, duplication and excessive bureaucracy. I can’t say I’m aware of any UK specific ratings that need this anymore, and with hindsight perhaps it has been a complexity that perhaps could have been avoided.

We also have the inconveniently named NPPL (National PPL Licence), which was a forerunner of the European LAPL. These can host a microlight rating (which is what most micropilots would have) and/or an SSEA rating (which allows the holder to fly a larger fixed wing aircraft).

As of 7 April 2020, none of the above three types of licence can be used to fly an EASA aircraft. The derogation that was given to enable that was not renewed. These licences remain valid for non- EASA aircraft and I don’t know of any plans to remove or discontinue them.

Aircraft Maintenance Regulations

There have been no alleviations or extensions for maintenance timescales. Aircraft Annuals, ARCs, 50 hour services (which also have a six month timeframe) all continue to apply. Your aircraft may not be legal to fly even if it has few hours since last service.

A significant change came into effect for light aircraft during March 2020, with the introduction of Part ML. For those flying private operations in aircraft less than 1200kg only (i.e. not flight training or commercial operations), this has less impact.

However, all flight schools and those owners of aircraft 1200kg or more will need to develop their own AMP (Annual Maintenance Program) and have this approved by their CAMO. An ARC (Annual Review Certificate) may not be able to be issued without one.

Many CAMOs may choose to downgrade to CAOs, which have fewer requirements but retain the most useful privileges required for general light aviation aircraft including ability to approve an AMP.

This is quite a complex change but has been poorly communicated to engineers and owners, so do read up on it and study the implications during the transition.

For those with Permit Aircraft, the LAA issued a statement about Permit Renewal which continues to operate by post as before. Permit Test Flights would of course be another matter entirely.

Private Pilots Licence — Cranfield Flying School

Students

Pilots in training could make good use of the downtime to study for their theory exams.

PPL and LAPL students will find that the introduction of e-Exams has been postponed from June to October. The existing paper exam questions will continue for the time being. Most clubs have restarted sitting of theory exams, and the UK CAA test centres for ATPL/CPL/IR exams reopened in July.

The maximum period of 18 months to pass all your PPL/ATPL theory exams have been extended by 6 months to 2 years. [ORS4 1353]

Last Updated 16 Aug 2020

5 comments

  1. Hi David

    Great writeup here.

    I tried to decipher the CAA rules too on Personal Medical Declaration…however, can you just clarify I think the PMD does not apply for IR(R) or IR privileges.

    So I guess that means we PPL holders will not be able to exercise those rights until they hold a full medical again.

    1. For EASA aircraft, you do need at least a Class 2 medical to fly IFR, which can remain valid using the exemption above.
      A PMD is sufficient to fly IFR only in a non-EASA aircraft with IMC rating privileges (not full IR privileges), and only in UK airspace.
      See CAA PMD webpage

  2. Thanks David for the time spent trawling thru the often ambiguous text in CAA docs, as did John.
    It is appreciated and the latest extensions shows a glimmer of light to reduce complexity for and the demand placed on the regulators keeping all sorts of red-tape scenarios simple. Hope you and family all well, Allan

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